Facts:

The case at hand is Nazario Marcelo vs. Clemencia Maniquis and Juan de la Cruz, which was decided by the Supreme Court of the Philippines on October 26, 1916. The dispute arose from a complaint filed by plaintiff Nazario Marcelo in the Court of First Instance of Nueva Ecija on August 15, 1911. Marcelo claimed to be the exclusive owner of a parcel of land located in the sitio of Tangos, barrio of Soledad, Santa Rosa, Nueva Ecija, which he detailed in terms of area, metes, and bounds in his title deed. He asserted that the defendants, Clemencia Maniquis and her husband Juan de la Cruz, unlawfully appropriated about two and a half cavanes of seed of the disputed land on or about July 11, 1911, causing him damages and losses. Marcelo requested a preliminary injunction to prevent further encroachment on his property and sought the payment of damages amounting to PHP 200.

The defendants, after a demurrer to the complaint was overruled, denied all allegations and claimed that they had

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Facts:

Background and Initiation of the Case

• Nazario Marcelo, the plaintiff, filed a written complaint on August 15, 1911, in the Court of First Instance of Nueva Ecija.
• The complaint alleged that Marcelo was the exclusive owner of a parcel of land in the sitio of Tangos, barrio of Soledad, pueblo of Santa Rosa, Nueva Ecija.
• The disputed land was described by its metes and bounds as shown in a title deed and further delineated in the complaint.

Claims and Relief Sought by the Plaintiff

• Marcelo claimed that the defendants (Clemencia Maniquis, her daughters, and Juan de la Cruz) had unlawfully appropriated part of his land measuring 212 cavanes of seed.
• He alleged that the defendants had been in possession of a portion of his property without his knowledge or consent since July 1911, leading to continuous damage.
• The plaintiff sought:
• A declaration of exclusive ownership over the land.
• An order enjoining the defendants from molesting his possession.
• Restoration and delivery of the parcel to him.
• Payment of damages and additional sums for losses, including fees for the surveyor’s work.

Defendant’s Special Defense and Alternative Claim

• The defendants contended that Clemencia Maniquis and her co-owners had been in quiet, public, and uninterrupted possession of the land for more than thirty years.
• They asserted that the land originally belonged to Mariano del Barrio, the late husband of Clemencia Maniquis, who had acquired it through a mortgage sale from Potenciano Marcelo.
• It was further maintained that following Mariano del Barrio’s possession, Clemencia Maniquis, along with her daughters, inherited the land and continued its possession legally over the years.

Evidence and Documentary Proof Adduced

• The plaintiff’s evidence included:
• A possessory information title issued on February 18, 1896, and entered in the property registry on June 19, 1896, covering the disputed parcel among others.
• Declarations and tax receipts showing that he had consistently paid the land tax from 1902 until 1911.
• Evidence against the plaintiff’s claim involved:
• Testimonies confirming the possession of the land by Mariano del Barrio and later by his widow, Clemencia Maniquis, and her daughters.
• A deed of sale (although not protocolized) dated May 6, 1893, through which Mariano del Barrio acquired a similar parcel.
• An ocular inspection and plan of the land (prepared by the court-appointed surveyor) showing that the boundaries of the disputed lot, as described in the possessory information, differed from those alleged by the plaintiff.

Procedural History and Developments

• At trial, after evidence was presented by both parties, the trial court rendered judgment in favor of the plaintiff on April 30, 1912.
• The defendants filed exceptions and moved for a reopening of the case and a new trial, which were overruled by the trial court.
• The case then reached the appellate court on a bill of exceptions raised by the defendants.

Issue:

Controversy as to the True Ownership

• Whether the plaintiff, Nazario Marcelo, had sufficiently proven his exclusive ownership of the disputed parcel of land through his possessory information title and other evidence.
• Whether the boundaries and identification of the parcel as claimed by the plaintiff conformed with the actual land held by the defendants.

Sufficiency of the Plaintiff’s Evidence

• Whether the evidence submitted by the plaintiff, including tax receipts and the possessory information title, adequately established his positive rights and the identity of the land in question.
• Whether the discrepancies in the description and boundaries between the plaintiff’s title and the actual possession undermine his claim.

Validity of Defendant’s Possession Claims

• Whether the continuous, quiet, and public possession by Clemencia Maniquis, her husband (Mariano del Barrio), and their heirs over many years substantiates their right to hold title over the disputed property.
• The impact of the admitted fact that adjoining landowners did not object to the possession proceedings initiated by the defendant’s predecessor in interest.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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